• videocam Live Webinar with Live Q&A
  • calendar_month September 8, 2026 @ 1:00 PM ET/10:00 AM PT
  • signal_cellular_alt Intermediate
  • card_travel Estate Planning
  • schedule 90 minutes

GST Trust Administration Challenges for Fiduciaries

Exemption Allocations, Severing GST Trusts, Investment Strategies in Exempt and Non-Exempt Trusts

Early Bird Pricing!
MSRP
$297.00
$252.45
Save $44.55

Discount expires 8/25/26

This course is $0 with these passes:

CLE
CPE
ALL
  1. keyboard_arrow_leftBack

About the Course

Introduction

This CLE/CPE course will provide estate planning counsel and fiduciaries with a practical guide to meeting the challenges of administering a generation-skipping transfer (GST) trust. The panel will discuss critical issues related to calculating the GST tax inclusion ratio and those involving both GST-exempt and non-exempt trusts, where tax consequences may arise from disproportionate allocation provisions. The webinar will also address implications and potential solutions to mixed inclusion ratio trusts to rehabilitate flawed planning.

Description

Critical to successful multi-generational gift tax planning and compliance is a solid foundation in the complex GST tax regime of Section 2632 and following statutes. Beyond identifying skip-person transferees and gifts that will trigger GST tax, fiduciaries must have a detailed understanding of the rules to calculate the tax cost of GSTs.

Section 2642 provides the framework for determining the taxable portion of any GST. The inclusion ratio works with the "applicable fraction" to determine the tax rate of a GST. A trust with an inclusion ratio of 0 is exempt from GST tax, while a trust with a ratio of 1 is fully taxable; either of these ratios is considered optimally efficient, depending on drafting and planning goals. However, post-death events often create challenges to existing allocation provisions.

Trustees or other parties such as trust protectors or directors with authority to effect distributions may have the power to make non-pro rata or non-per stirpes allocations of GST exemption amounts, even in cases where the decedent has distributed property on a pro rata basis.

Additionally, the fiduciary may be able to sever a GST trust into separate instruments. Depending on the asset makeup, a fiduciary may also tailor investment decisions to minimize the GST tax impact of transfers, such as having the GST-exempt trust invest in growth assets that produce minimal trust accounting income to distribute.

Listen as our experienced panel provides a practical guide to the tax-efficient administration of GST trusts.

Presented By

Susan K. Dromsky-Reed
Member
Brach Eichler, LLC

Ms. Dromsky-Reed concentrates her practice in estate planning and estate administration. She provides individuals and families with advice regarding spousal, intergenerational, business succession, charitable planning and preparation of prenuptial agreements. Ms. Dromsky-Reed is a Fellow of the American College of Trust and Estate counsel and is a frequent author and lecturer on estate planning and administration.

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio
Joy Matak, Esq.
Member
Brach Eichler, LLC

Ms. Matak is a member of Brach Eichler LLC in the firm’s Trusts and Estates practice group. She brings a unique perspective as an income tax specialist gained from years working in public accounting, helping clients save current income taxes with strategies that also achieve business succession, asset protection, life insurance structuring and estate planning goals. Ms. Matak serves on the editorial board of Trusts & Estates magazine for which she co-authors the print journal’s bi-monthly column Practical Practice Solutions, and regularly contributes thought leadership to Tax Management Estates, Gifts and Trusts (BNA) Journal; Leimberg Information Services, Inc. (LISI); and Estate Planning Review The CCH Journal, among others, on a variety of topics including wealth transfer strategies, income taxation of trusts and estates, and business succession planning. She co-authored a book on the 2017 tax reforms entitled Estate Planning: Estate, Tax and Other Planning after the Tax Cuts and Jobs Act of 2017.

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio
Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • CPE credit is not available on recordings.

  • BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).


  • Live Online


    On Demand

Date + Time

  • event

    Tuesday, September 8, 2026

  • schedule

    1:00 PM ET/10:00 AM PT

I. IRC 2642 structure

A. Inclusion ratio defined

B. Applicable fraction defined

C. Treatment of inclusion ratios in the severance of GST-impacted trust into two or more trusts

II. Post-mortem events and transfers requiring recomputation of inclusion ratio and the appropriate fraction

III. Making non-pro rata or non-per stirpes allocations of property disposed of on a pro rata or per stirpital basis by a testator

IV. Trust severance rules and opportunities

V. Investment strategies to minimize GST impact on transfers

VI. Roles of various fiduciary and administrative persons

The panel will review these and other relevant topics:

  • How to spot trusts with an inclusion ratio greater than 0
  • Proactively identifying valuation opportunities when calculating inclusion ratios
  • The interrelation between inclusion ratio and the applicable fraction under Section 2642 and its regulations
  • Special rules for CLATs and other types of trusts in the calculation of inclusion ratio and the imposition of GST tax
  • Regulatory guidance for calculating numerator and denominator of applicable fractions


Learning Objectives

After completing this course, you will be able to:

  • Discern the factors needed to calculate the numerator and denominator of the GST applicable fraction
  • Determine how to compute the inclusion ratio for a GST trust
  • Recognize exceptions for CLATs and other specific trusts to the inclusion ratio computation rules
  • Identify planning opportunities through pre-transfer inclusion ratio calculations in structuring and funding trusts subject to GST tax
  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite:

    Three years+ business or public firm experience at mid-level within the organization preparing complex trust forms and schedules. Specific knowledge of estate and gift tax rules, fiduciary accounting, and GST rules; basic familiarity with exemption calculations, generation skipping tax calculations and portability of spousal lifetime exclusions.

BARBRI, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .